Earlier this month, a federal jury found reality television stars Todd and Julie Chrisley guilty of multiple counts of conspiracy, bank fraud, wire fraud, and tax evasion.
According to prosecutors, in addition to nontax crimes, the Chrisleys failed to file tax returns or pay any taxes for the 2013, 2014, 2015, and 2016 tax years. The Chrisleys’ accountant, Peter Tarantino, was also convicted of filing two false corporate tax returns on their behalf.
The publicity surrounding the case was expected. The Chrisleys are involved in several media projects, including television shows, and have a popular podcast. The convictions should, according to James E. Dorsey, special agent in charge, IRS-Criminal Investigation (IRS-CI), “send a clear message regardless of your fame or notoriety, everyone will be held accountable for paying their fair share of taxes.”
Making these kinds of cases public causes taxpayers to wonder: What constitutes a tax crime?
Let’s start with what it’s not. It’s not just a mistake. Most tax crimes require an element of willfulness. You’ll see that reflected in statutory subheadings like “Willful failure to file return, supply information, or pay tax” (26 USC § 7203) and in statutory text like “Willfully makes and subscribes any return, statement, or other document, which contains or is verified by a written declaration that it is made under the penalties of perjury, and which he does not believe to be true and correct as to every...
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